Mola Education Ltda. (MOLA), registered with the CNPJ under No. 21.294.575/0001-34, with an e-mail address: privacy@molamodel.com, headquartered at Rua Xerentes, No. 57, Perdizes, CEP 05.008-020, São Paulo/SP, Brazil, presents to its users, in general, its Privacy Policy.

We at MOLA are committed to protecting your privacy and your personal data. This Privacy Policy describes the privacy and security practices implemented in the collection, use, and other steps of the treatment of personal information on our company's website.

This document regulates how MOLA will take care of the Personal Data collected and stored when using the website or other ways, such as by email.

We follow international standards for the protection of personal data, safeguarding the rights of data subjects around the world. However, as our company is headquartered in Brazil, we will use some expressions in reference to the Brazilian General Data Protection Law (LGPD), which has protection parameters like the European Data Protection Regulation (GDPR) and other laws in other countries.

Through this Policy, you will be aware of the collection, storage, and use when you decide to contract and use our services or any other feature, technology, or functionality that we offer when accessing our website, or by any other means (collectively “the Mola Services”).

This Policy also tells you how to exercise your rights relating to these personal data processing activities.

Before reading this document, make sure you have accessed and agreed to our Terms and Conditions of Service at https://molamodel.com/policies/terms-of-service.

MOLA may modify this Privacy Policy through information published on its website (www.molamodel.com) or by registered email to improve, adapt or update it to legislative or jurisprudential changes.

Attention: The use of our website, with the provision of your personal data, occurs by the content of this Privacy Policy. Thus, if the User does not agree with any of the defined conditions, it is recommended that he disable access without providing his/her personal data or even contacting us by e-mail privacy@molamodel.com.

1. General Terms And Definitions

1.1. For the purposes of this document ("Privacy Policy"), the following terms and definitions shall be considered:

Personal Data: is information related to a natural person and capable of identifying the person or making it possible for him to be identified. Examples of personal data that may allow your identification are: Name, ID, telephone, email, license plate, etc.;

Sensitive Personal Data: Personal Data on racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person;

Digital Identification Data: are those related to the IP address, recording of interactions with the website, installed applications, and cookies;

Data Protection Officer – DPO: is the person appointed to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).

Database: is the set of personal and sensitive data, established in one or several places, in electronic or physical support, exclusively owned by MOLA;

Data Subject: you, the natural person to whom the personal data that are the object of processing refer;

Treatment: any operation performed with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion or extraction;

Consent: is the free, informed, and unambiguous expression by which the holder agrees with the processing of their Personal Data for a specific purpose;

Free Access: it is the guarantee to holders of free and easy consultation on the form and duration of data processing, as well as on the completeness of their personal data;

IP: is the set of numbers that identify the computer or mobile device used to access the website; and

Cookies: are files sent by the website server to the user's computer or mobile device to identify and obtain access data, such as browsed pages or clicked links, thus allowing the personalization of the use of the website.

2. What Data Is Collected And How?

2.1. When you visit the MOLA website, we collect your IP address and standard web access information, such as your browser type and the pages you visit on our website.

2.2. If you wish to hire MOLA's services, the following types of information will be collected:

a) Registration Data – These are the personal data required to register a customer on the MOLA website, to fulfill the contract, namely: Name and surname, ID, email, full delivery address, billing, and other similar information;

b) Financial information of Customer Users – credit card data that will be processed by partner payment methods when requesting the MOLA Services;

c) Budget Data: These are the personal data requested through a specific form to budget MOLA's services, for contract fulfillment, in budgets for legal entities in Brazil, complementary to the data of legal entities that hire our services. Some optional data may be collected for profiling, which will help us customize the Budget in more detail;

d) When using MOLA's Services, information will be collected about your computer or other access devices for fraud prevention and usage data for analysis to generate service improvements; and

e) Communications between you and MOLA: information relating to communications between you and MOLA, via email, telephone, social networks (WhatsApp, Telegram, among others).

2.3. Data may be stored on Brazil and/or abroad servers.

3. How Is The Data Used?

3.1 Your personal data may be used for the following purposes:

a) provide the services and support to the customer, when requested;
b) enable the purchase of products and/or services;
c) process transactions and send notices about your transactions;
d) prevent potentially prohibited and/or illegal activities and ensure the application of our User Agreement;
e) redirect the user to the most suitable website (Brazil or International)
f) customize, evaluate and improve our services, in addition to the content and layout of our website;
g) compare information, for greater accuracy, and verify it with third parties;
h) comply with existing legal requirements, to which the MOLA is subject, such as, but not restricted to, tax, fiscal, criminal requirements, among others;
i) perform internal organizational procedures, prepare productivity, sales, and billing reports, prepare customer satisfaction studies and create business intelligence indicators;
j) detect, prevent and/or remedy undue changes to our systems and records, or actions that may put the website and its Users at risk to prevent and prevent the occurrence of fraud; and
k) send you targeted marketing materials, service update notices, and promotional offers based on your preferences;
l) review and rate your reviews and/or products.

3.2. Your personal information will not be sold or rented to third parties, for any purpose, without your explicit consent. We may combine your information with data from other companies to improve and personalize our services. If you do not want to receive marketing messages from us or participate in our ad personalization programs, simply email us at privacy@molamodel.com or click on the unsubscribe link provided in all of our emails.

4. What Legal Basis Authorizes Data Processing?

4.1. All operations with personal data that we carry out are supported by hypotheses (legal bases) provided for in the LGPD, according to the purposes and particularities of the case.

4.2. Among the legal bases used by us to authorize the processing of data we carry out, there are:

a) Consent (Art. 7, I, LGPD): In cases where there are no other legal hypotheses, we may request your free, unambiguous, and informed consent so that we can process your data. Furthermore, the consent given may be revoked at any time, free of charge and easily;

b) Compliance with a legal or regulatory obligation (Art. 7, II, LGPD): In some instances, we will need to comply with a legal or regulatory obligation, such as the requirement to maintain records of access to our website or our applications, in respect to article 15 of Law No. 12,965/2014 (“Marco Civil da Internet”), or compliance with the applicable fiscal and tax rules, without prejudice to other rules that generate data processing obligations;
c) Execution of a contract or preliminary procedures related to the agreement (Art. 7, V, LGPD): When you contract our services, we establish a contractual relationship with you based on your adherence to the Terms of Service of our website to gain access to the features and facilities we offer. In these cases, we will process your data as necessary to fulfill the contractual obligations assumed by us. An example of this treatment is collecting and processing your full name, email, and telephone number so that we can link your registration to the website. In addition, when you are interested in hiring our services, we may process your personal data from your request so that we can contact you in order to understand the particularities of your business and how we can help (preliminary procedures to the contract);
d) Regular exercise of rights (Art. 7, VI, LGPD): The processing of your personal data may also be supported by this legal basis when there is a need to ensure the regular exercise of our rights in contracts and any administrative actions, judicial or arbitration;
e) Legitimate interest (Art. 7, IX, LGPD): When we have a legitimate interest in the processing of your personal data, except for the case in which your fundamental rights and freedoms prevail, such processing will occur based on the legitimate interest, observing all the legal requirements set out in the LGPD, such as the preparation of tests and reports that attest to the treatment based on this hypothesis;
f) Credit protection (Art. 7, X, LGPD): The processing of personal data may also be supported by the need for credit protection, when applicable. An example of this treatment is the case in which it is necessary to verify your condition of paying for the products or services offered by us;
g) Guarantee of fraud prevention and security of the holder (Art. 11, II, “g” LGPD): We will process your personal data when necessary to guarantee fraud prevention and its security in the identification and authentication processes of records in electronic systems.

5. Where And How Do We Store Your Personal Data?

5.1. The personal data used are stored in the cloud, on servers (data centers) of large companies destined for this purpose - which may be located both in national territory and abroad -, with which we maintain a contract and all the criteria of security of this information. We carry out, with our partners, assessments about the privacy and protection of personal data so that personal data are treated following applicable legislation and provide the necessary guarantees for the security of information to minimize any risks.

5.2. The partners with whom we share your data for storage and processing purposes are:

Partners

Service Description

Google Drive

(https://www.google.com)

File storage and synchronization service

Hubspot

(https://br.hubspot.com)

An inbound marketing tool that manages and automates routines for attracting, retaining, and converting leads.

5.3. Personal data are kept in these cloud storage environments for the period in which they are necessary for the purposes for which they were collected or until the Data subject requests the deletion of such data when such data are treated based on consent. Furthermore, the data will continue to be stored - even without the consent of the holder - when the retention of such data is supported or required by law or when it is necessary to satisfy a legitimate interest (for example: for auditing, security, fraud control purposes or preservation of rights).

6. Who Has Access To Data?

6.1. MOLA may share your personal data, on a legal basis independent of consent, with service providers under contract, who collaborate in parts of MOLA's commercial operations (fraud prevention, collection activities, marketing, technology services), as well as to improve the products or services offered or in case MOLA has external partners that provide web hosting or maintenance services.

6.1.1. MOLA may share personal data with its internal team and with the following categories of companies:

Our Partners and Suppliers: We may share Personal Data with partners and/or suppliers. Our partners and suppliers are only authorized to use Personal Data for the specific purposes they were contracted.

Some examples of current partners with whom we may share your Personal Data are:

Partners

Service Description

Association of Engineers (NCSEA)

(http://www.ncsea.com/)

Discount validation for associate members.

Facebook Pixel

(https://pt-br.facebook.com/business/learn/

facebook-ads-pixel) 

Analytical tool to help measure the success of a sponsored campaign based on a code inserted on each page of your website.

Pipedrive

(https://www.pipedrive.com)

Sales customer relationship management tool.

Fedex, DHL, UPS, Shipsmart, Correios, Gadol Apps

(https://www.fedex.com); (https://www.dhl.com);
(https://www.ups.com);

(https://www.shipsmart.com.br);

(https://www.correios.com.br); e

(https://www.gadolapps.com).

Express delivery of correspondence, documents, and objects.

Omie

(https://www.omie.com.br) 

Management system for issuing invoices.

Shopify

(https://www.shopify.com.br)

E-commerce platform to sell on the internet.

Mailchimp

(https://mailchimp.com/pt-br/)

Sales customer relationship management tool.

6.2. MOLA undertakes to determine, in its contracts, that these service providers only use your information concerning the services they perform for MOLA and not for their benefit.

6.3. Police, judicial or regulatory authorities may have access to your personal data, if necessary to comply with a legal, contractual or administrative obligation, especially when:

a) MOLA is obliged to do so by subpoena, court order, or similar legal procedure; and

b) MOLA is cooperating with an ongoing police investigation.

6.4. In cases where MOLA and a partner promote their Services together, MOLA may disclose to the partner some personal information, such as full name, address, and username of the persons who registered for the Services as a result of the joint promotion, with the sole purpose of allowing MOLA and the partner to assess the results of the promotion.

6.4.1. In this case, the partner will not use personal information for any other purpose.

7. How Long Will We Keep Your Data?

7.1 MOLA will keep your Personal Data for the entire period in which you remain registered on the Site and, after that, only within the established legal period.

7.2 The Personal Data collected will be deleted from MOLA's databases when requested by the holder of the Personal Data, or when they are no longer necessary or relevant to offer the Services provided, unless there is any other reason for their maintenance, as a possible legal obligation to the retention of data, or the need to preserve them for the protection of rights.

8. How Do We Protect Your Data?

8.1 MOLA adopts technical and administrative measures to protect personal data from unauthorized access and accidental or illegal situations of destruction, loss, alteration, communication, or dissemination. Despite the security measures adopted, we cannot guarantee total security against hackers or third parties using methods to obtain information improperly. Unauthorized use of accounts, hardware or software failure, and other factors may compromise the security of your Personal Data at any time.

8.2 MOLA also relies on the collaboration of users to monitor and increasingly implement security in our treatment activities. Thus, besides implementing good security practices, the user can contact our communication channel by e-mail: privacy@molamodel.com if he identifies or becomes aware of any suspicious activity that could compromise his personal data security.

9. International Transfer

9.1 MOLA contracts cloud storage services with some companies, specifically Google Drive, whose data centers are located abroad. Some of these international locations do not have data protection laws similar to the LGPD, in which case we will take reasonable measures that are within our power to ensure the protection of Personal Data following applicable privacy and data protection laws (such as contractual clauses, terms amendments on data protection, compliance with international standards, display of seals, certificates and/or adopted codes of conduct).

We adopt the applicable contractual and security measures at our disposal to ensure that the transfer of data to these countries does not violate the rights of data subjects provided for in data protection regulations, especially the LGPD.

10. E-Mail Marketing Policy

10.1. The sending of email marketing is within the standards established by the relevant legislation and codification, including under the terms of the Self-Regulation Code for the Practice of Email Marketing (CAPEM), which provides for the use of this marketing tool based on ethics and in liability, without prejudice to the simultaneous application of the applicable legislation in force.

10.2. MOLA is against sending emails without prior authorization (Anti-SPAM Policy). The use, by the company mentioned above, of data confirmation/registration with executable attachments (exe, com, scr, bat) and download/archive links is non-existent. If you do not wish to receive marketing messages from us, simply indicate your preference by emailing us at privacy@molamodel.com or clicking on the unsubscribe link provided in all of our emails.

11. Cookies

11.1. Cookies are files created by frequented websites that record browsing information, allowing the User to stay connected while remembering their software preferences and providing targeted content.

11.2. When you access the MOLA website, small data files called “cookies” may be placed on your computer, this includes the companies that MOLA hires to monitor how the website is used.

11.3. A “session cookie” will be sent to your computer when you log into your account or use MOLA Services. This type of cookie helps to recognize you if you visit multiple pages on the site during the same session, so you don't have to ask for your password on every page. After you log out or close your browser, this cookie may last for up to 30 days and be renewed each time the web application is accessed.

11.4. You may encounter third-party cookies when using MOLA's Services on specific websites that are not under the control of MOLA (for example, if you view a webpage created by a third party or use an application developed by a third party, a cookie may be placed by that page or application).

11.5. Users can control the use of cookies in their browser settings, except for the login cookie, which will only cease to exist after they log out of the site. If you reject cookies, you can still use our website, but your ability to use some features or areas of our website may be limited.

11.6. The software access cookie is disabled when the user leaves the MOLA website and all its subdomains.

12. How To Exercise Your Rights?

12.1 The Brazilian General Law for the Protection of Personal Data (Law nº 13.709/2018 - LGPD) guarantees you specific rights and guarantees concerning your personal data. MOLA, fulfilling its obligation of clarity and transparency, in addition to detailing in this policy how it uses and protects your personal data, provides, on this link, a free and facilitated channel for you to exercise your rights to:

- Request Information about the treatment of your personal data: You can confirm that we carry out the treatment of your personal data, request access to them and correction of incorrect data; request a list of all agents with whom we share your data;

- Correction: If you find that the data we hold about you is inaccurate, incomplete, or out of date, you can request a correction.

- Sharing information: You have the right to know who your personal data is shared with, so you can ask us for this information. Depending on the case, we may limit the information provided to you if its disclosure could violate our intellectual property or business secret. If you have consented for any purpose of processing your Personal Data, you can always choose to withdraw your consent. However, this will not affect the legality of any Treatment carried out before revocation. If you withdraw your consent, we may not provide you with certain services, but we will notify you when this occurs.

- Request the deletion or anonymization of personal data: You have the right to ask us to anonymize or permanently delete your data if they prove to be unnecessary or excessive for processing, or if they are being treated in disagreement with the LGPD;

- Revocation of consent: You have the right to object to the processing activity using your refusal of consent or by revoking it, being, in these cases, aware that the impossibility of processing your data may make access to services or functionalities.

12.2. If you request the deletion of all data included on the website, via e-mail or the website, this will result in the impossibility of accessing any of the features of the MOLA website, as well as its subsequent recovery, except for those whose storage is mandatory by the law.

12.3. You can also contact our data manager at privacy@molamodel.com. In cases where we act as Personal Data Operators, we will not be able to meet requests made directly by the Data Subject, as such requests must be made directly to the Data Controller. Therefore, in cases where it is impossible to meet the Cardholder's requests, we will explain the reasons that justify this non-compliance, always observing the provisions of the LGPD.

13. Children's Data

13.1. The MOLA website is not intended for children (under fourteen). Therefore, children are not expected to enter their personal data on our website or intentionally collect information from this audience. If parents or legal representatives believe that their children have provided us with personal information, they may contact us by emailing us at privacy@molamodel.com.

14. How Will Changes In Privacy Policy Be Informed?

14.1. This Privacy Policy may change at any time, so it is essential to pay attention to your e-mail address, as it will be through this means that MOLA will inform you of any changes.

14.2. You may not accept the new terms of the Privacy Policy. Still, in this case, your account will be automatically terminated, as acceptance of the Terms of Use and this Privacy Policy are prerequisites for using the website.

15. Contact And Questions

If you have any questions regarding compliance with this Privacy Policy, you should contact our DPO through the email below.

E-MAIL: privacy@molamodel.com

Address: Rua Xerentes, No. 57, Perdizes, CEP 05008-020, São Paulo/SP, Brazil.